1 Batterymarch Park, Quincy, MA Phone: Fax: M E M O R A N D U M

Transcription

1 National Fire Protection Association 1 Batterymarch Park, Quincy, MA Phone: Fax: M E M O R A N D U M TO: FROM: NFPA Technical Committee on Aircraft Rescue and Fire Fighting Ken Holland, Staff Liaison DATE: March 9, 2012 SUBJECT: NFPA 403 ROP TC Circulation Ballot, A2013 Cycle The March 8, 2012 deadline for receipt of the NFPA 403 ROP letter ballot has ended. The preliminary ROP ballot results are as follows: 29 Members Eligible to Vote 3 (Deniston, Greenup, Voisine) In accordance with the NFPA Regulations Governing Committee Projects, attached are reasons for negative votes for review so you may change your ballot if you wish. Abstentions and affirmative comments are also included. Ballots received from alternate members are not included unless the ballot from the principal member was not received. If you wish to change your vote, the change must be received at NFPA on or before March 16, Members who have not returned a ballot may do so now. Such changes should be sent to Yvonne Smith via either to ysmith@nfpa.org or via fax to You may also mail your ballot to the attention of Yvonne Smith at NFPA, 1 Batterymarch Park, Quincy, MA (to arrive no later than March 16, 2012). The return of ballots is required by the Regulations Governing Committee Projects. Attachment: Circulation Explanation Report

2 Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : 3 Entire Document (Log # CP1 ) Steyn, D. Comma after "The need for," needs to be removed Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : (Log # CP2 ) Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : (Log # CP3 ) Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : 3 2.2, 2.3.1, and (Log # CP4 ) Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : (Log # 2 )

3 Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : Aircraft Fire Fighting, Aircraft Incident, A.3.3.4, and A (New) (Log # 3 ) Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : Aqueous Film-Forming Foam (AFFF), Film-Forming Fluoroprotein Foam (FFFP), Fluoroprotein Foam Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : (Log # CP8 ) Pierce, D. Change..."such"... with..."emergency"... (clarification) Delete..."the environs of"... (unnecessary) Eligible To Vote:29 Affirmative: 25 : 1 Abstain: 0 : , 4.2.1, 4.2.2, and (Log # CP6 ) Lawler, M : Airport Full Scale Exercises contains "tested every two years" and this two-year reference should be change to be be consistent with the next log, (Log #4), recommendation to change from two to three years intervals. Three years should be the requirement. Phillips, P. The language in is not consistent with what was agreed to in the next log (403-10, Log #4). Three years, not two.

4 Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : (Log # 4 ) Davidson, R. While changing the frequency of full scale exercises from every two to every three years is acceptable, the committee should avoid subtantiations that imply that this standard must be in line with mandated FAA FAR 139 requirements. Traditionally this standard has been considered superior to FAR 139 and has evolved independently of FAA requirements Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : 3 Table (Log # CP9 ) Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : (Log # CP11 ) Eligible To Vote:29 Affirmative: 25 : 1 Abstain: 0 : (Log # CP12 )

5 4 Davidson, R. The cited EN 1568 test standard is not the only test method against which fluorine-free synthetic foams could be listed. For example UL 162, which is cited in , includes the testing and listing of synthetic foams (defined by UL as a liquid concentrate that has a base other than fluorinated surfactant or hydrolyzed protein ). Other internationally recognized test methods could also be applicable to fluorine-free synthetic foams. Suggest that fluorine-free synthetic foams be included in existing In the appendix in A5.1.2 it currently mentions that other international test methods may be acceptable to the AHJ. In A5.1.2 it could be stated that EN 1568 has been used to test fluorine-free foams and is an example of an acceptable non-u.s test method Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : (Log # CP19 ) Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : 3 Table 5.3.1(a) and Table 5.3.1(b) (Log # CP13 ) Eligible To Vote:29 Affirmative: 21 : 5 Abstain: 0 : 3 Table 5.3.1(a) and Table 5.3.1(b) (Log # CP16 ) Davidson, R. The changes in the column labeled response capability (sec) represents a reduction in life safety compared to the current edition of 403. Maximum time to deliver Q1 is increased from 120 to 180 seconds, Q2 from 180 to 210 seconds and Q3 from 240 to 420 seconds. The probability of passenger survivability in a fuselage threatened by fire is lessened if response time is increased. Reducing the level of life safety from the previous edition of 403 would be contrary to the purpose of the standard as stated in paragraph The principal objective is to save lives. It would also be in conflict with the Committee Scope which places particular emphasis on saving lives and reducing injuries coincident with aircraft fires following impact or aircraft ground fires.

6 5 Krause, R. Although I know the work in this area was very detailed, I would prefer to have the work and new calculations related to agent quantities validated by an independent party prior to updating the manual with this new information. Lawler, M. The time changes recommended for the charts are directly related to the recommendation to change response times from two minutes to three minutes in paragraph My non-concur rationale contained in paragraph applies here as well: The development of the two minute response time, as currently written, required years of research and study and is principally based on the science of survivability of aircraft occupants when in aircraft accidents involved in fire, no matter what the frequency. The sole rationale to change this standard now is based on only the fact that many ARFF Departments can't achieve a two minute response time and therefore changing the standard will give them relief. The NFPA Standard should not merely reflect what the ARFF services can achieve it should also reflect the science of what the ARFF services should achieve. One could argue that no progress has been made over the last twenty years in the United States at selecting new fire station locations to help meet the 2 minute response time. This is because, in America airports use the FAA Part 139 three minute standard and as such have not been compelled to locate new station according to the two minute standard. Merely changing the standard to facilitate the same time as the FAA is counter to the years of efforts which led to the current two minute standard. Mathis, R. These changes were based on a presentation but we have yet to see the official report. I would like to see the numbers and the final recommendations verified by an independent third party before changing the document. Scheffey, J. see rationale provided with negative vote; note, this negative vote is applicable to the time change only, not the agent change for double deck aircraft, which I agree with. These are two separate technical issues and should be balloted separately Eligible To Vote:29 Affirmative: 22 : 3 Abstain: 1 : 3 Table 5.3.1(a) and Table 5.3.1(b) (Log # CP10 ) Bordeleau, P. Should be subscript E not F. The current edition of NFPA 403 has only subscript a-d and there is no other mention in the committee ROP that adds another subscript besides this one. Krause, R. Although I know the work in this area was very detailed, I would prefer to have the work and new calculations related to agent quantities validated by an independent party prior to updating the manual with this new information. Mathis, R. These changes were based on a presentation but we have yet to see the official report. I would like to see the numbers and the final recommendations verified by an independent third party before changing the document. Abstain

7 6 Phillips, P. I'm not inclined to vote on this item until I've had the opportunity to review the complete report Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : (Log # CP7 ) Eligible To Vote:29 Affirmative: 23 : 3 Abstain: 0 : (Log # 5 ) Colet, R. Rationale is not applied universally. 2 times 3,000 gallons rationale with FFFP and protein does not add up. Davidson, R. Reducing the number of vehicles responding in Cat 7 airfields could negatively affect life safety. Compared to two vehicles, three vehicles provide a tactical advantage in fighting a fire and also provide greater redundancy for assuring an adequate delivery capability. The committee should not be reducing the level of life safety inherent in the current standard. Also the committee's stated substantiation for approving this change is not relevant - adherence to FAA FAR 139 has never historically been, nor should it be, a factor influencing the requirements of this standard. Lawler, M. Maintain current text or modify current text for Cat 7 airport by adding in the chart a 2 or 3 vehicle option. A change in the table to (2) two vehicles will remove flexibility from the AHJ to determine ARFF fleet mix. The rationale provided for making the recommended change is too limiting and takes away from the AHJ authority. Steyn, D. There is no defined relationship in NFPA between volume of water required at the scene, and the number of trucks required to carry that volume of water. Tonnacliff, M. Stephen Listerman, Cincinnati/NKy International Airport FD Revise text to read as follows: Category 7 lists number of required vehicles as three. Suggest a change to two. The FAA FAR 139 requirement for Index C (Category 7) ARFF vehicles is two or three vehicles based on total water carried. An ARFF department may be able to supply the needed water with only two vehicles. Two gallon vehicles exceed the recommended water in Table Justification is incorrect - 14 CFR Part requires Index C airport to have two or three vehicles totaling 3000 gals of water not two 3,000 gal vehicles as stated Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : and (Log # CP37 )

8 Eligible To Vote:29 Affirmative: 25 : 1 Abstain: 0 : (Log # CP17 ) Bordeleau, P. should also add NFPA 402, NFPA 414 refers back to NFPA 402 for a listing of all rescue tools required to be carried on an ARFF vehicle Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : (Log # CP21 ) Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : (Log # CP20 ) Eligible To Vote:29 Affirmative: 22 : 4 Abstain: 0 : (Log # CP22 )

9 8 Bordeleau, P. The reference provided at the committee meeting and stated in the substantiation (2005 ARAC ARFFRWG final report page 104 and 105) list the time as five minutes and not four minutes. If we are going to use this reference as the bases for this decision then we need to either state we are going to raise the standard against what is written within the standard or comply with the report. Colet, R. Rationale is not consistent to statement: "Shall demonstrate the ability to apply." Davidson, R. The proposal increases the maximum time for starting the application of Q3 from four minutes to seven minutes (three minutes for initial response plus four minutes). This potentially represents a reduction in life saving capability and is not an appropriate action for this committee (see Reason/Comment for Proposal above). Lawler, M. The existing standard of 4 minutes from time of alarm to a new standard four minutes from time on scene is not sufficiently substantiated with the rationale provided; i.e. not enough evidence to overturn the existing standard. Getting water on the fire is critical to enhancing occupant survival; taking four minutes after arrival to deploy and HRET or hand line for aircraft with interior fires is excessive. Day, G. Amend text to read "Responding units shall include qualified personnel trained and equipped for cabin interior fire fighting" (See recommendation in 8.1.4) Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : (Log # CP23 ) Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : (Log # CP24 ) Eligible To Vote:29 Affirmative: 19 : 7 Abstain: 0 : (Log # CP25 )

10 9 Bagot, K. The initial change in this Log is to add 1 minute to the operational runway which I can support. The substantiation and meeting discussions, in my opinion, did not justify the 1.5 minute increase to the on-airport portion of the RRA with improved surface conditions. 1 minute should have been added to both requirements. Colet, R. Total disregard for 1. established scientifically arrived at consensus by respected international mix of committee members for decades 2. NFPA guidelines. Davidson, R. The probability of passenger survivability in a fuselage threatened by fire is lessened if response time is increased. Reducing the level of life safety from the previous edition of 403 would be contrary to the purpose of the standard as stated in paragraph The principal objective is to save lives. It would also be in conflict with the Committee Scope which places particular emphasis on saving lives and reducing injuries coincident with aircraft fires following impact or aircraft ground fires. Lawler, M. The development of the two minute response time, as currently written, required years of research and study and is principally based on the science of survivability of aircraft occupants when in aircraft accidents involved in fire, no matter what the frequency. The sole rationale to change this standard now is based on only the fact that many ARFF Departments can't achieve a two minute response time and therefore changing the standard will give them relief. The NFPA Standard should not merely reflect what the ARFF services can achieve it should also reflect the science of what the ARFF services should achieve. One could argue that no progress has been made over the last twenty years in the United States at selecting new fire station locations to help meet the 2 minute response time. This is because, in America airports use the FAA Part 139 three minute standard and as such have not been compelled to locate new station according to the two minute standard. Merely changing the standard to facilitate the same time as the FAA is counter to the years of efforts which led to the current two minute standard. Scheffey, J. No true technical justification was provided. The original rationale for these changes was the information contained in the report Determination of Evacuation and Firefighting Times Based on an Analysis of Aircraft Accident Fire Survivability Data May 2009 by R. Cherry. This report makes no conclusions or recommendations related to required response time. When pressed in committee to give the technical rationale, the substantiation in committee was then changed to correlate with ICAO and FAA. Now it is back to the Cherry report, which provides no technical basis for the change. The Cherry report only describes how long vehicles take to respond in actual incidents, some of which are off the airport site. The basis of response time was discussed in a presentation earlier in the meeting: 3 minutes is the assumed burn through ( may be optimistic), so the response time must be two minutes, plus the one minute control time, to assure occupant safety within the 3 minutes. The new requirement would exceed this level of safety. NFPA 403 has, in many cases, been more restrictive than adopted regulations. This has led regulators to consider the higher level of safety embodied in NFPA 403. The 2 minute criteria, included in the standard for decades, should be retained. Steyn, D. Not enough data provided to substantiate a change in standard. Tonnacliff, M. Substantiation does not support two minute increase in time to RRA.

11 10 Bordeleau, P. NFPA 402 states The survivable atmosphere inside an aircraft fuselage involved in an exterior fuel fire is limited to approximately 3 minutes if the integrity of the airframe is maintained during the impact. This time could be substantially reduced if the fuselage is fractured. When the aluminum skin is directly exposed to flame, burnthrough will occur within 60 seconds or less, while the windows and insulation may withstand penetration for up to 3 minutes. Because of this serious life hazard to occupants, rapid fire control is critical. Therefore, whenever flight operations are in progress, ARFF vehicles and personnel should be located so that optimum response and fire control can be achieved within this time frame. Based on NFPA 402 standard provided above and that according to the reference provide at the committee meeting for this change by raising the time from two minutes to three minutes. We would meet the requirement fifty percent of the time equaling twenty-seven out of the fifty-four responses, by keeping the current standard we would meet the requirement thirty-four out of the fifty-four responses. I believe that lowering the standard so that we can meet the standard is not enough justification and equates to whittling a square peg to fit into a round hole Eligible To Vote:29 Affirmative: 23 : 2 Abstain: 1 : (Log # CP26 ) Bagot, K appears to missing a location in the text. What is the location we are responding to in both optimum conditions of visibility and surface conditions. Tonnacliff, M is confusing and misunderstanding. Wording need to be changed. We are not responding to visibility and surface conditions. Abstain Colet, R. Not comfortable with the final wording.

12 11 Matheson, G. For clarity, the new text proposed under could be corrected as cited below: The plan shall include expectations regarding the number of minutes to respond in optimum conditions of visibility and surface conditions However for consistency with the new wording under section 9.1.3* Response Time, as well as my understanding of the NFPA Manual of Style, I believe that the new text of sections and should be incorporated as cited below: 9.1.4* Plan Airport ARFF services shall develop/implement a plan for responding to an incident/accident involving any aircraft with passengers within the aircraft movement area beyond or outside the runway and RRA The plan shall include expectations regarding the number of minutes to respond All response times shall be in optimum conditions of visibility and surface conditions Although I advocate the latter edit that eliminates the designation of a new section (9.1.5), either one will not change the intent of this proposal. Thus, I am voting in the Affirmative with comment Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : 3 Table A (Log # CP27 ) Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : 3 A.5.2 (Log # CP14 )

13 12 Colton, B. In reading over some of the historical language in the original appendix wording, there are additional changes needed. For instance, there is wording indicating reduced visibility when using halogenated agents, which is true for other complimentary agents, but not halogenated agents. I would suggest additional revisions to this appendix language as follows: A.5.2(2) Halogenated extinguishing agents are hydrocarbons in which one or more hydrogen atoms have been replaced by atoms from the halogen series --fluorine, chlorine, bromine, or iodine. This substitution confers not only non-flammability but flame extinguishment properties to many of the resulting compounds. Halogenated agents are used both in portable fire extinguishers and in extinguishing systems. The three halogen elements commonly found in extinguishing agents are fluorine (F), chlorine (Cl), and bromine (Br). Extinguishing mechanisms vary for halogenated extinguishing agents. The primary extinguishing mechanism for Halon 1211 acted by chemically interrupting the continuing combination of the fuel radicals with oxygen in the flame chain reactions. This process is known as chain breaking. Halogenated agents that have replaced Halon 1211 primarily act by increasing the heat capacity of the air within the fire zone. This results in a cooling of the fire by removing heat that the reaction needs to sustain the flame. The discharge of halogenated agents can create hazards to personnel such as dizziness, impaired coordination, reduced visibility, and exposure to toxic agent decomposition products. Breathing apparatus should be worn during flightline and rescue operations. In any proposed use of halogenated agents where there is a possibility that people might be trapped in or enter into atmospheres made hazardous, suitable safeguards should be provided to ensure prompt evacuation of, means for prompt rescue of any trapped personnel, and to prevent unprotected entry into, such atmospheres and also to provide means for prompt rescue of any trapped personnel. Breathing apparatus should be worn. Halogenated agents leavesleave no agent residue and are the preferred agent for aircraft tire fires involving, engine fires, interior aircraft fires, engines, electrical and hydraulic componentscomponent fires, avionics, and wheel assemblies. They are also the preferred agent for and flightline vehicle orand aircraft service equipment engine fires. Due to its ozone depleting properties, production of new Halon 1211 stopped in 1994 and discharge of agent for training was no longer allowed. In June 1995, the FAA certified HCFC Blend B as an acceptable alternate agent to Halon 1211 for ARFF, FAA Cert-Alert Like Halon 1211, HCFC Blend B is a clean extinguishing agent effective on Class A, B, and C hazards. It does not leave a residue after application, and therefore minimal or no collateral damage occurs from the agent itself to equipment and other assets in the area where it is employed. Due to its ozone depleting properties, production of new Halon 1211 stopped in 1994 and discharge of Halon 1211 for training is no longer allowed Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : 3 A.5.5 (Log # CP15 ) Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : 3 A (Log # CP18 ) Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : 3 Annex B (Log # CP28 )

14 Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : 3 Annex C (Log # CP29 ) Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : 3 D.4 and Table D.14 (Log # CP32 ) Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : 3 D.6 and D.8 (Log # CP30 ) Pierce, D. Change "RFFS" to "ARFF" in all instances. This was approved by the committee throughout the document Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : 3 D.9 (Log # CP31 ) Pierce, D. Change..."in" an airport... to..."on" an airport... Proper grammar, sp? Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : 3 Table D.14 (Log # CP33 )

15 Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : 3 Annex E (Log # CP34 ) Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : 3 E.4 (Log # CP35 ) Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : 3 F.1.1, F.1.2.5, and F (Log # CP36 ) Bagot, K. If you are removing the version letters from the referenced Advisory Circulars, then you need to remove the publications dates as well. Davidson, R. The international test standard for fluorine-free synthetic foam mentioned in proposal # (EN 1568) should be added to the list of references. Tonnacliff, M. The changes made to the FAA Advisory Circulars (AC) removing the Letter designator/version (i.e. A, B, C) is ok, but when the date of the version of AC remains, it makes no since, since you give the date of the document and therefore you are not referencing the current document, you are referencing an old document which may have been updated or even deleted. Recommend remove date associated with the AC along with the letter designation/version Eligible To Vote:29 Affirmative: 26 : 0 Abstain: 0 : 3 F (Log # 1 )

16 15 Bagot, K. The committee statement only references the removal of the letter designations for the FAA ACs. The action was to remove both the letters and the issue dates. Tonnacliff, M. See my statement on Proposal (Log #CP36) that addresses to this log.